IS 6 FT FROM AN UNPROTECTED EDGE adequate clearance to meet the federal OSHA requirements for employee fall protection safety? This myth and several other common misconceptions are the subject of this article. Since its inception, OSHA has had a profound influence on the workplace, especially through the 29 CFR 1910 (general industry) and 29 CFR 1926 (construction) regulations. As with most rules promoting a change of conduct, confusion exists regarding the interpretation of these rules and questions about fall protection are among them. This confusion is evidenced by the issuance of more than 365 letters of interpretation by OSHA for fall protection alone in response to questions seeking clarification. Over the years, many managers, workers and SH&E professionals have become “self-interpreters,” reaching conclusions that do not conform to either the standards or the published interpretations. Consequently, several myths have become prevalent and convenient standards of conduct despite the fact that they are erroneous, do not provide proper worker protection and are citable. Because of these myths, some may conclude that many SH&E professionals are either not aware of or do not consider the letters of interpretation or proposed rulemaking standards issued by OSHA. Both of these tools are approved by OSHA for the development of procedures and enforcement of work rules, providing the best information available for worker safety. Several myths and/or misconceptions have been promulgated to the point that they have become accepted facts, at least until an incident occurs and OSHA becomes involved. The initial question in this article is one such myth. It is a common misconception that the worker is safe and in compliance as long as a distance of 6 ft is maintained from an unprotected edge. However, no such carte blanche rule exists and never has in the OSHA regulations. To examine some of the common myths and misconceptions, this article focuses on OSHA 29 CFR 1910 Subpart D, Walking-Working Surfaces, and Subpart I, PPE; 29 CFR 1926 Subpart M, Fall Protection and Subpart X, Stairways and Ladders; and the letters of interpretation and proposed rulemaking concerning fall protection. Steel erection, residential construction, aerial lifts and other fall protection issues are not covered. Compliance issues may be different than those presented if operations are being conducted under a state plan. Another myth is the generally stated belief that a state plan is as stringent or more stringent than federal OSHA. Comparison may prove otherwise.
Letters of Interpretation& Proposed Rulemaking Many SH&E professionals are aware of these tools and diligently use them, yet most people outside of the profession are not aware of these tools. Both are readily accessible on OSHA's website (www.osha.gov). On the right-hand side of the site, under Laws & Regulations, visitors will see links to both standards and interpretations. A search in the interpretations section using the term
fall protection returns 369 results. This information can be sorted by relevance or title. Sorting by title works best because the date is always first in the title and this provides a chronological reference.